Private letter ruling
From Wikipedia, the free encyclopedia
Private letter rulings (PLRs), in the United States, are written decisions by the Internal Revenue Service (IRS) in response to taxpayer requests for guidance.[1] A letter ruling is "a written statement issued to a taxpayer by an Associate Chief Counsel Office of the Office of Chief Counsel or by the Tax Exempt and Government Entities Division that interprets and applies the tax laws to a specific set of facts."[2]
A letter ruling binds both the IRS and the requesting taxpayer (in the event the matter is further disputed or litigated) but only those parties, so the ruling may not be relied on as precedent by other taxpayers. The IRS has the option, however, of redacting the personal content of a letter ruling and issuing that content as a revenue ruling, which may become binding on all taxpayers and the IRS.
PLRs from 1997 onwards are available to the public through the IRS Electronic reading room (see 26 U.S.C. § 6110).